To: Winona County Commissioners


From: Jim Riddle and Eric Nelson

Supervisors, Winona County SWCD

December 30, 2011

We urge the Winona County Board to find answers to questions regarding frac sand mining in the county prior to issuing any permits. Time will be needed to find the answers, therefore, we urge the County Board to establish a one-year moratorium on permits for frac sand mining.

We appreciate the thoughtful approach that the county has taken and the opportunities you have provided for public input. Despite the research that has been conducted, we find that many questions remain unanswered, including:

If frac sans mines are allowed, at what point are there too many sand trucks per mile of road and per hour of operation?

At what point, does the county -

charge for road repair?

charge for road upgrade?

limit truck traffic to achieve noise abatement and disturbance to neighbors?

limit truck traffic for road safety issues, such as school bus routes, intersections, and entrances to main roads (left turn especially)?

limit trucking, blasting, and acres of strip mines to not reduce property values?

What steps can/should the county take to maintain the scenic beauty of the region?

As per language in the County Ordinance, how does the county make certain that frac sand mining will not create an excessive burden on existing parks, schools, streets/roads, and other public facilities and utilities which serve or are proposed to serve the area?

With sand trucks coming into Winona County from neighboring counties and from Wisconsin, how can Winona County best work with regional counties and the State governments of Wisconsin and Minnesota to regulate the number of sand trucks per mile of road per hour of operation to equitably assess costs for impacts?

Has the county moved forward on a multi-county agreement, as mentioned by Jason Gilman?

What steps can be taken by the county to mitigate loss of unique habitats in St. Peter sand deposits, the Rochester Plateau, and mined formations?

Consider establishing a sand prairie mitigation requirement, similar to wetland mitigation, where prairies are protected at a 4 to 1 ratio – in other words, for each acre lost, provide permanent protection to 4 acres from mining development. Any native restored prairie established to mitigate damage would need to have comparable species composition/biodiversity and support comparable mammals, birds, reptiles, amphibians, and insects, compared to destroyed habitat. What are the mechanisms to achieve prairie ecosystem mitigation?

Can the county require that mining occur only on previously degraded lands, in order to protect rare ecosystems?

How many sand mines can simultaneously operate in Winona County?

How can the county legally say “no” to any, once they’ve said “yes” to some? The “density” issue has been mentioned by some mining proponents, but the legal mechanisms to regulate/limit density have not been explored or developed.

How will frac sand mining affect property and land values and the ability of beginning farmers to get established? What is likely to happen to land values, after sand mines have closed?

How will frac sand mining and processing affect water quality in Winona County and the city of Winona? Silica sand formations currently function as a filter of our water. If this natural filter is removed, how will this affect water quality?

If mines are permitted, what restrictions will be placed on “reclaimed” land to protect groundwater recharge areas from farm chemicals and industrial contaminants? (For example, can the county require that the reclaimed land be farmed according to USDA organic production requirements; placed in permanent pasture; or restored to prairie vegetation, in order to protect vulnerable groundwater?)

How will mining affect air quality? What are the potential adverse health impacts?

Do the targeted areas contain any Indian burials sites, pioneer cemeteries, or Amish graves?

Do the areas contain habitat for Federally listed species, such as Karner’s Blue butterflies?

Due to the extent of landscape change being proposed, shouldn’t an Environmental Impact Statement be completed prior to any permits being issued?

We would like to take this opportunity to inform you that the Winona County Soil and Water Conservation District is in the process of developing a multi-county application to provide Reinvest in Minnesota (RIM) conservation easements to landowners in the Rochester Plateau to protect prairies, habitat for rare species, and groundwater recharge areas. If approved, this will provide an economic incentive to protect, rather than destroy the landscape. We cannot submit our application to the state until April, however.

Thank you for listening. As elected officials, we have a responsibility to protect the health, safety, and quality of life in Winona County, today, and into the future.

In order to fulfill your elected duties, the issues we have listed above must be fully investigated.


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